Patterson v. Six Flags Theme Parks, Inc.

Summary

The United States District Court for the Eastern District of California entered a permanent injunction after finding Six Flags Theme Parks, Inc., Six Flags Entertainment Corporation, and Park Management Corporation liable for failing to accommodate Melvin Patterson’s hearing disability under Title III of the Americans with Disabilities Act and California’s Unruh Civil Rights Act. The injunction requires specified accessibility procedures for Six Flags Discovery Kingdom and the national call center, including ASL interpreter request processing, staff training, interpreter-provider agreements, video remote interpreting, documentation, and compliance reporting. The court limited the injunction to Discovery Kingdom and the call center’s interactions with guests seeking accommodations for visits to Discovery Kingdom.

Holdings

1. The injunction may bind the defendants, persons in active concert or participation with them who have actual notice, and successors in interest, and the proposed injunction did not improperly enjoin parties under Rule 65.
2. The requirement that defendants make Video Remote Interpreting available as an emergency, brief-communication, or guest-requested accommodation was within the scope of the permanent injunction.
3. The injunction was overbroad to the extent it applied to all Six Flags parks; the permanent injunction was limited to Six Flags Discovery Kingdom and the national call center's interactions with guests seeking accommodations for Discovery Kingdom.

Questions Presented

1. Whether the permanent injunction could bind Six Flags parties, affiliated entities, successors, and persons in active concert or participation with the defendants under Federal Rule of Civil Procedure 65.
2. Whether the proposed injunction was overbroad because it required Video Remote Interpreting services and imposed requirements beyond the specific accommodation previously identified in the court's findings.
3. Whether the proposed injunction was overbroad because it applied to all Six Flags parks rather than only Six Flags Discovery Kingdom and the national call center.

Disposition

other